Kansspelautoriteit orders Endorphina to block its games from unlicensed Dutch sites

The Kansspelautoriteit issued a binding instruction on 19 October 2026 requiring Endorphina Limited (Malta) and Endorphina Ltd. (Cyprus) to take measures to stop their games appearing on unlicensed gambling sites accessible from the Netherlands, and ordered Endorphina to report back within two weeks of the decision date. The instruction, published by the KSA on 2 November 2026, does not impose a fine but cites a breach of Article 1(1)(b) of the Betting and Gaming Act (Wet op de kansspelen).

The KSA's decision and required measures

Signed under Article 34n of the Betting and Gaming Act, the decision is a binding instruction rather than a penalty order. It requires Endorphina to implement “adequate measures” against promoting unlicensed gambling in the Netherlands and to inform the regulator of those measures within two weeks of the decision date. The KSA lists technical and contractual measures with operators and distributors that take Endorphina's games as examples of steps the studio should use.

Supervisors recorded test plays of Endorphina titles on Dutch IP addresses in January and February 2026, in June 2026, and on 29 and 30 September 2026. The KSA names 28 domains where the games were playable, including instantcasino.com, betiro.com, betblast.com, fastslots.com, goldenpanda.com, sambaslots.com and winningz.com; the decision identifies these seven as run by EOD Code, the operator the KSA fined a record €37.25 million in October 2026. The KSA also found titles playable on qbet.com and luckygem.com, despite those operators being under penalty orders.

Endorphina's responses and the KSA's rebuttals

The record of correspondence shows the KSA first contacted Endorphina on 2 April 2026. Endorphina replied on 7 May 2026 citing contractual confidentiality, and on 14 May 2026 denying evidence it knowingly supplied illegal operators. In written views on the proposed instruction Endorphina argued that its Maltese and Cypriot companies are distinct, that licences, contracts and remote servers differ between the two entities, and that it distributes through licensed B2B intermediaries. Endorphina also stated that in July 2026 it restricted access on every site named by the KSA, while not admitting a breach.

The KSA rejected each defence. Its decision notes the two companies filed identical views through the same contact person and coordinated measures; a redacted chart included in the decision shows one person listed as director of the Cypriot company and sole shareholder of the Maltese company. The KSA says Endorphina did not supply the results of its investigation, that the company's name and logo appeared on the unlicensed sites, and that game URLs and game-level labelling showed Endorphina's presence. The regulator records that intent and the question of which entity supplied the games are irrelevant to imposing a binding instruction.

Legal and enforcement context

The KSA treats the presence of Endorphina titles on unlicensed domains as promotion of unlicensed gambling, prohibited under Article 1(1)(b) of the Betting and Gaming Act. The decision characterises a visible supplier brand and playable titles on unlicensed sites as factors making those sites look trustworthy, and it frames the instruction as a warning to other suppliers as well as a remedy directed at a studio.

Dutch enforcement historically focused on operators and payment or internet intermediaries; the KSA's published decision notes prior actions, including penalty orders in 2019 against Gaming Innovation Group and Innovation Labs for advertising unlicensed operators. The KSA says it is also working with Google on an EU white list to assist enforcement.

A binding instruction is the softer enforcement tool the KSA uses where an intermediary may be providing crucial services without knowledge of the illicit activity. The regulator's publication decision observes that after six months of correspondence and published findings, that rationale is harder to apply to a game supplier that, according to the KSA, had the information and means to act. The decision does not specify a particular sanction if Endorphina fails to comply, and it records that Endorphina may object to the instruction within six weeks; lodging an objection would not suspend the instruction.

Overlap with regulated markets and commercial activity

The KSA notes Endorphina's titles are also supplied to licensed Dutch operators, and that using the same titles on unlicensed sites creates a channelisation risk by lending familiarity to illegal offerings. On the day the KSA published its decision, 2 November 2026, Endorphina announced a commercial partnership with PointsBet Canada for Ontario and described Hell Hot 100 and Crown Coins among its popular titles in that market.

What the decision records and next steps

The decision (ref. 01.414.929) records the test plays, lists the 28 domains, reproduces the correspondence between the KSA and Endorphina, summarises Endorphina's views and the KSA's responses, and sets the two-week reporting deadline from 19 October 2026. The KSA published a separate publication decision on 2 November 2026 (ref. 01.414.933) explaining the rationale for publication and noting the case serves as a warning to other game suppliers. Endorphina can file an objection within six weeks of the decision date; the company had not published a response to the KSA's instruction as of 2 November 2026.

For reference, the KSA decision is available in the regulator's published documents and was captured by the KSA on 2 November 2026. The KSA's instruction to Endorphina can be read as an enforcement step directed at a content supplier rather than an operator, and compliance will be tested by subsequent checks rather than the paperwork alone. Interested readers can view the regulator's document and related materials in the KSA's publication of 2 November 2026. binding instruction PointsBet Canada announcement games studio actions